Thank you for your letter dated February 8, requesting guidance on the
proper recording of illnesses on the OSHA 200 Log. Your letter was forwarded
to my office from the Directorate of Compliance Programs. The Division of
Recordkeeping Requirements is responsible for the administration of the
injury and illness recordkeeping system nationwide.

For recordkeeping purposes, an occupational illness is any abnormal
condition or disorder resulting from a non-instantaneous event or exposure
within the work environment. Any such job related abnormality reported to
the employer is recordable, whether or not functional impairment is present
or lost workdays are involved (see Q&As E-8 and E-9 on page 41 of the
Recordkeeping Guidelines for Occupational Injuries and Illnesses).

An illness is considered work related if an exposure at work either caused
or contributed to the onset of symptoms or aggravated existing symptoms to
the point that they meet OSHA recordability criteria. Moreover, if it seems
likely that an event or exposure within the work environment either
contributed to or aggravated the condition, it is considered work related
(see Q&A B-17, page 32 of the Recordkeeping Guidelines). Therefore, unless
the illness was caused solely by a non-work related event or exposure off
premises, the case is presumed to be work related. If the physician is able
to say that an employee's lung scarring was in no way contributed to or
aggravated by the dust exposure (or any other exposure) within the work
environment, then the case would not be considered work related, and
therefore not recordable. If the condition is determined to be recordable,
the case(s) should be recorded as Dust Diseases of the Lungs, column 7(b) on
the Log.

When recording occupational illnesses, enter the date of initial diagnosis
or recognition of the illness, or, if absence from work occurred before
diagnosis, enter the first day of absence attributable to the illness which
was later diagnosed or detected (see page 9 of the Recordkeeping Guidelines).

If a work related illness is discovered within 5 years after the employee
retires, the case should be recorded in the year of occurrence if the date of
the onset of illness can be identified. If not, the case should be recorded
in the retiree's last year of employment (see Q&A E-5, on page 23 of the
Recordkeeping Guidelines).

I hope you find this information useful. If you have any further questions,
please call us at Area Code (202) 219-6463.

Sincerely,

Bob Whitmore
Chief
Division of Recordkeeping Requirements

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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